Employer Alert: Action Required as ARPA COBRA Subsidies End September 30th
Under the American Rescue Plan, separated employees who elect COBRA continuation coverage because of involuntary job loss or reduction in hours have been eligible to apply for premium assistance coverage. The government has been covering 100% of their COBRA premiums and will continue to do so through Sept. 30, 2021.
Through the ARPA, the premium will be reimbursed directly to the employer, plan administrator, or insurance company through a COBRA premium assistance credit.
The program has been in place since March of this year. For a refresher, here is a link to the DOL’s FAQs addressing the FAQS ABOUT COBRA PREMIUM ASSISTANCE.
With the program coming to an end next month, the Department of Labor has developed a model Notice of Expiration of Period of Premium Assistance that plans may use to satisfy certain notice requirements under the ARPA. The notice can be accessed here: Notice of Expiration of Period of Premium Assistance. The DOL considers appropriate use of the model notice to be good faith compliance with the notice of expiration and it is also important to note that to use the model notice properly, the Plan Administrator must fill in the blanks with the appropriate plan information.